What the new BPA rules mean for inks, coatings, and varnishes in food packaging

22 sept. 2026

Epoxy-based coatings have been a workhorse of food packaging for decades, but now that era is closing. As of 20 July 2026, the European Union’s ban on bisphenol A (BPA) in food contact materials has passed its main compliance deadline, meaning the food packaging value chain finds itself operating under a fundamentally new regulatory reality.

Here is what’s changed, what it means for food packaging industry, and how Flint Group Packaging Solutions is positioned in response.

What has changed with BPA regulations?

Toxicological concern over BPA exposure has been building for years, in large part driven by a 2023 European Food Safety Authority (EFSA) reassessment that found current exposure levels posed risks to consumers across all age groups. These findings contributed to the implementation of Commission Regulation (EU) 2024/3190 in December 2024, which prohibits the use of BPA and its salts (along with other hazardous bisphenol derivatives) in the manufacture of Food Contact Materials and articles.

The regulation entered into force on 20 January 2025 with an 18-month transition period that ended on 20 July 2026. From that date, most single-use and repeat-use food contact articles manufactured using BPA can no longer be first placed on the EU market.

This has prompted manufacturers of epoxy-based Food Contact Materials in particular to fundamentally rethink formulation strategies. If any BPA-based resin systems are still used in food packaging must now be replaced with alternative chemistries or validated BPA-free solutions.

Regulation (EU) 2024/3190, in brief

Regulation (EU) 2024/3190 rests on three core prohibitions:

Article 3: Prohibits the intentional use of BPA and its salts in the manufacture of Food Contact Materials.

Article 4: Prohibits residuals of BPA if another bisphenol or bisphenol derivative has been used in the manufacture of Food Contact Materials.

Article 5: Prohibits the intentional use of hazardous bisphenols or hazardous bisphenol derivatives in the manufacture of Food Contact Materials. Hazardous bisphenols or bisphenol derivates are defined as those with a harmonised classification as carcinogenic, mutagenic, or toxic to reproduction (CMR category 1A or 1B), or as an endocrine disruptor for human health (category 1) according to CLP Regulation (EC) No 1272/2008.

How to demonstrate compliance with Regulation (EU) 2024/3190

Compliance with the regulation can be demonstrated by providing supporting documentation proving that BPA has not been intentionally used in the manufacture of a Food Contact Material.

The regulation sets a detection limit of 1 ppb for two cases where BPA, its derivatives or other bisphenols are intentionally used:

BPA is used as a monomer or starting substance under the exception in Annex II.
A bisphenol other than BPA, or a bisphenol derivative, is used in accordance with Article

In both cases, the 1 ppb limit is used to confirm that the food-contact material (FCM) does not contain or release any residual BPA. Compliance must be verified through an extraction test using a method sensitive enough to meet this detection limit.

Neither case applies to Flint Group Packaging Solutions, so no testing is required.

Flint Group Packaging Solutions' position and EuPIA's approach

The degree of scrutiny placed on BPA in food contact materials has led to the packaging ink value chain largely pre-empting the current requirements. BPA and its derivatives are not intentionally used in printing inks for food packaging applications at Flint Group Packaging Solutions. This means compliance with Regulation (EU) 2024/3190 can be demonstrated by a chain of custody approach, without a testing obligation.

However, use of BPA is so widespread across industrial supply chains that it cannot be entirely ruled out as a trace impurity in certain raw materials. One additional potential source of traces of Bisphenol A that would need to be explicitly mentioned, are the inner coating of containers either of raw materials delivered to printing ink manufacturers or those used for the delivery of the finished product. In many cases the protective internal coating is based on epoxy resins and thus BPA.

BPA-free coated pails and drums also remain limited in the market, and since this affects raw materials upstream it is not something that ink manufacturers can fully control on their own.

Flint Group Packaging Solutions continues to work within EuPIA’s framework with strict Good Manufacturing Practice, careful raw material selection, and modern risk assessment methods. EuPIA members are committed to setting the highest standards for providing safe ink formulations for food contact use and to reduce residual BPA as much as possible.

A global issue

Although the EU is leading the shift away from BPA, other markets are also moving toward compatible restrictions. Brand owners are also frequently ahead of legislators, building the absence of BPA and related substances into their own internal compliance requirements regardless of jurisdiction. As a result, many are coming to see BPA-free formulations as a core baseline expectation regardless of where they are located.

Where you can find more support on the BPA topic?

If you have questions about compliance documentation, raw material sourcing, or Flint Group Packaging Solutions’ BPA-free ink and coating portfolio, our technical and regulatory teams are ready to help.